Key Take Aways
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There exists a rare ‘once in 25 years’ opportunity to revolutionise vulnerability data-sharing in essential sectors, including financial services.
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Success hinges on adopting a human-centric approach that tackles consumer disincentives and logistical barriers to disclosure.
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Consistent, shared terminology around ‘data-sharing’, ‘disclosure’, and ‘vulnerability’ is vital to reduce misunderstandings and build trust.
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Systems should prioritise delivering actionable support over mere flags, preventing redundant disclosures and enhancing customer experience.
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Consumer control, transparency, and accessible digital portals are fundamental to fostering trust and enabling active participation.
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Clarifying organisational purposes within data-sharing networks enhances consumer awareness and confidence in data use.
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Organisations across sectors do not require uniform lawful processing bases; operational flexibility is key to cross-sector collaboration.
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Engaging consumers with lived experience builds trust and ensures data-sharing solutions are relevant and effective.
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Dynamic architectures that allow consumers to review and revoke disclosures promote ongoing agency and control.
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Rapid, accessible support must be embedded in systems, particularly in emergency or time-sensitive situations.
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Continuous monitoring for future risks—including misuse of data by AI and machine learning—is essential to prevent harm.
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Achieving this potential requires a multi-stakeholder approach involving consumers, regulators, and providers to embed fair, transparent processes.
Key Statistics
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Approximately 14 million adults in the UK are disabled; 25 million are vulnerable.
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Only 11–14% of vulnerable consumers have disclosed support or vulnerability needs to an essential service provider.
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70% of vulnerable consumers report difficulties interacting with service providers due to health conditions.
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Up to 73% of consumers with mental health issues would consider disclosure if system design addressed trust, security, and regulation.
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Nearly 40% of disabled adults feel they cannot access or use many essential services due to inadequate support or adjustments.
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The energy and water Priority Services Register (PSR) has begun progress towards cross-sector data sharing, with pilot schemes starting in 2024.
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Over 35,000 staff across 350 firms have participated in consumer vulnerability programmes via the Money Advice Trust.
Key Discussion Points
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The strategic importance of a sector-wide, human-centric approach that prioritises consumer control and accessibility.
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The necessity for standardised terminology to prevent misunderstandings and foster trust among stakeholders.
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Addressing barriers such as fear, complexity, and inaccessible channels that impede disclosures.
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Emphasising actionable support needs over higher-level flags, to reduce multiple disclosures and improve user experience.
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The critical role of accessible digital portals that empower consumers to manage disclosures proactively.
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Ensuring transparency around data use policies as new organisations join sharing networks.
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Providing legal flexibility in processing bases to facilitate dynamic, cross-sector data exchanges.
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The value of co-design and engagement with consumers with lived experience to enhance trustworthiness.
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Embedding review and revocation options that enable consumers to revise or withdraw disclosures as their circumstances evolve.
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The importance of ongoing oversight to prevent future harms, including AI misuse and re-identification risks.
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The necessity for multi-sector collaboration driven by shared principles and a focus on consumer empowerment.
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Recognising this moment as a ‘once in 25 years’ opportunity to embed systemic, equitable, and accessible processes impacting millions of vulnerable consumers.
Document Description
This article explores a critical and unprecedented opportunity to transform vulnerability data-sharing within essential services, including financial, energy, water, and telecom sectors. It highlights core principles for designing systems that are fair, transparent, and accessible, with a focus on empowering vulnerable consumers. Through expert insights and practical examples, the article underscores the importance of a collaborative, human-centric approach to unlock significant benefits—minimising harm, reducing complexity, and fostering trust across sectors. It provides strategic guidance for senior managers aiming to lead ethical, effective, and future-proof data-sharing reforms.
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